The ARRC sent a letter to the U.S. Treasury Department and the Internal Revenue Service about the proposed regulations regarding guidance on the IBOR transition. The letter describes the proposed regulations as “comprehensive” and “addressing most of the concerns raised by the ARRC in a manner that gives significant flexibility to taxpayers seeking to transition away from IBORs.” In the letter, the ARRC provided a number of recommendations intended to facilitate market participants’ ability to rely on the proposed regulations as they act to transition legacy IBOR contracts.

The ARRC released a proposal for New York State legislation which is intended to minimize legal uncertainty and adverse economic impacts associated with LIBOR transition. The ARRC is publishing this proposed legislation to promote broader engagement.

The ARRC released a consultation on swaptions based on U.S. dollar (USD) LIBOR that could be affected by the discounting change for cleared derivatives from the use of the Effective Federal Funds Rate (EFFR) to the Secured Overnight Financing Rate (SOFR) effective at the close of business on October 16, 2020.

Submitting Feedback about this Consultation
The ARRC welcomes responses to the consultation from the widest possible range of stakeholders, who may be impacted by these changes. The release of the consultation marks the start of a public comment period during which the ARRC intends to work closely with stakeholders to solicit and incorporate their input. Following this comment period, the ARRC plans to determine whether it should recommend a compensation methodology for swaptions referencing USD LIBOR.

Responses to the consultation may be submitted by email to the ARRC Secretariat (arrc@ny.frb.org) no later than March 9, 2020. Please coordinate internally and provide only one response per institution. Please attach your responses in a PDF document and clearly indicate "Consultation Response" in the subject line of your email.

Comments will be posted on the ARRC's website as they are received without alteration except when necessary for technical reasons. Comments will be posted with attribution unless respondents request anonymity. If your institution is requesting anonymity, please clearly indicate this in the body of your email and please ensure that the PDF document you submit is anonymized. Questions regarding the consultations should also be sent to the ARRC Secretariat (arrc@ny.frb.org) and will not be posted for attribution.

The ARRC released a survey to help software and technology vendors assess their readiness to transition to SOFR. The survey also serves as a platform for vendors to raise operational issues to the ARRC.

Submitting Responses
As noted in the letter that accompanies the survey, the ARRC asks vendors to input responses to Section I in the spreadsheet, and submit the spreadsheet by email to the ARRC Secretariat (arrc@ny.frb.org) by March 16, 2020. Please do not submit any responses to Section II. Indicate "Vendor Survey" in the subject line of your email, and provide only one response per institution.

Webcast Details
ARRC representatives hosted a webcast on Monday, February 10, 2020 to answer vendors' questions. A recording of the webcast can be viewed via this link.

The ARRC released a buy-side checklist, which outlines the steps for an effective shift to SOFR, and is designed to be used alongside the User's Guide to SOFR. It is similar to the practical implementation checklist released in 2019, but is more narrowly intended for use by buy-side firms.

The ARRC released final recommendations for new interdealer cross-currency basis swaps that use the Secured Overnight Financing Rate (SOFR) and overnight risk-free rates (RFRs) recommended by National Working Groups (NWGs) in other jurisdictions. The conventions outlined in this document are for market participants’ voluntary use.

The ARRC released a consultation on spread adjustment methodologies for cash products referencing U.S. dollar (USD) LIBOR. These spread adjustments are intended for use in USD LIBOR contracts that have incorporated the ARRC's recommended hardwired fallback language, or for legacy USD LIBOR contracts where a spread-adjusted SOFR can be selected as a fallback.

Submitting Feedback about this Consultation
The ARRC welcomes responses to the consultation from the widest possible range of stakeholders. The release of the consultation marks the start of a public comment period during which the ARRC intends to work closely with stakeholders to solicit and incorporate their input. Following this comment period, the ARRC plans to recommend spread adjustments that would apply to its fallback recommendations.

Market participants may submit responses to the consultation questions by email to the ARRC Secretariat (arrc@ny.frb.org) no later than March 6, 2020. Please provide only one response per institution. Please attach your responses in a PDF document and clearly indicate "Consultation Response" in the subject line of your email. Comments will be posted on the ARRC's website as they are received without alteration except when necessary for technical reasons.

Comments will be posted with attribution unless respondents request anonymity. If your institution is requesting anonymity, please clearly indicate this in the body of your email and please ensure that the PDF document you submit is anonymized. Questions regarding the consultations should be sent to the ARRC Secretariat (arrc@ny.frb.org) and will not be posted for attribution.

The chair of the ARRC's Tax Subgroup released a letter requesting IRS and Treasury guidance regarding the anticipated International Swaps and Derivatives Association Protocol relating to Interbank Offered Rate ("IBOR") fallback provisions. Subsequently, the ARRC's Tax Subgroup counsel submitted a follow-up letter to the IRS and Treasury on December 20, 2019, to provide examples of bilateral amendments and to highlight additional issues that should be considered in the interim guidance relating to the Protocol. The Subgroup also submitted an additional follow-up letter on January 30, 2020.

The ARRC released a comment letter to the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Reserve Deposit Insurance Corporation, the Farm Credit Administration, and the Federal Housing Finance Agency (together, the "Agencies") in response to the Agencies' notice of proposed rulemaking regarding margin and capital requirements for covered swap entities. Consistent with the ARRC's mandate, the ARRC's comment letter focuses on the provisions of the proposed rule designed to facilitate an orderly transition away from interbank offered rates. The ARRC released a supplemental comment letter on February 13, 2020 that addresses swaption transactions.

The Chair of the ARRC's Accounting and Tax Working Group released a letter to the Securities and Exchange Commission (SEC) that sets out the ARRC's understanding that the SEC staff does not object to the conclusions that certain amendments to preferred shares would be accounted for as a modification, rather than an extinguishment, and that such a modification would not result in the recognition of an exchange of value.

The Matrix linked above identifies considerations relevant to using SOFR in new floating rate notes (FRNs) and the Appendix includes SOFR FRN term sheets and fallback language. The Comparison Chart highlights key differences of structures used in the market. These documents were developed to help market participants as they consider issuing or investing in SOFR-based FRNs and may be updated or supplemented periodically. The Matrix and Comparison Chart were issued on August 1, 2019, while the Appendix was issued on November 21, 2019.

The ARRC released a letter to the Commodity Futures Trading Commission regarding regulatory issues associated with the transition of derivatives contracts from interbank offered rates to alternative risk-free benchmarks. The letter updates and consolidates earlier letters from the ARRC to the CFTC requesting regulatory clarification on the same subject.

ARRC, in conjunction with Securities Industry and Financial Markets Association (SIFMA), submitted a comment letter in response to Financial Accounting Standards Board's (FASB) Exposure Draft on reference rate reform. The letter is also available here.

This set of frequently asked questions, which is updated from time to time to reflect developments, provides information about the work of ARRC, its progress to date and the overall effort to promote voluntary market adoption of its recommended alternative to USD LIBOR, the SOFR.

ARRC previously issued a press release when the frequently asked questions were initially published on September 20, 2018. The ARRC has since updated this document on an ongoing basis.

ARRC released a practical implementation checklist to help market participants transition to using the Secured Overnight Financing Rate (SOFR), which is the ARRC's recommended alternative to U.S. dollar (USD) LIBOR.

ARRC released a letter to the U.S. Securities and Exchange Commission (SEC) requesting confirmation that preferred stock instruments that reference LIBOR qualify for the same relief that the Financial Accounting Standards Board (FASB) has proposed for other contracts referencing interbank offer rates (IBORs), including LIBOR.

ARRC's Consumer Products Working Group developed this white paper detailing how an average of the Secured Overnight Financing Rate (SOFR) can be used in newly issued adjustable-rate mortgages (ARMs) in a structure that is comparable to today's existing ARM loans. A one-page summary of the white paper can be found here.

ARRC released guiding principles for the development of fallback contract language for consumer products and defined the scope of work for its Consumer Products Working Group. While the Consumer Products Working Group is relying on many of the lessons learned by the ARRC's other working groups that developed recommended fallback language this year for market participants' voluntary use in a range of cash products, this Group's work also faces a unique set of circumstances that require additional consideration given that stakeholders include retail consumers.

This report details preliminary considerations for the use of risk-free rates (RFRs) in interdealer cross-currency swaps.

Following the ARRC's letter to the U.S. Treasury requesting guidance on tax issues that arise as a result of the market transition from LIBOR and other Interbank Offered Rates, the ARRC submitted these documents to the U.S. Treasury with proposals to further address some of the tax concerns highlighted in the letter.

This document complements the ARRC's Paced Transition Plan by outlining key priorities and milestones in 2019 to support and prepare market participants for the transition.

ARRC released a follow-up to its July 2018 letter to U.S. regulators regarding regulatory issues associated with the transition of derivatives contracts from interbank offered rates to alternative risk-free benchmarks. The follow-up letter responds to regulators’ requests by describing different models market participants may use to effect the transition, and also requests that new derivatives linked to SOFR and other alternative rates that are not subject to mandatory clearing be exempt from initial margin requirements for a limited amount of time in order to build liquidity in the market. Note that while the letter published here is addressed to the CFTC, identical letters were sent to all of the U.S. regulatory addressees with only the addressee and regulator name changed.

This document highlights progress made since the Federal Reserve Bank of New York, in collaboration with the Office of Financial Research, began daily publication of the SOFR in 2018.

ARRC released a white paper to help explain how market participants can use its recommended alternative to U.S. dollar LIBOR, the Secured Overnight Financing Rate (SOFR), in cash products. This paper builds on the ARRC’s work developing the Paced Transition Plan, which outlines the steps for an effective shift to SOFR.

ARRC released a letter requesting guidance on tax issues that arise as a result of the market transition from LIBOR and other Interbank Offered Rates to alternative risk-free rate benchmarks.

ARRC released a letter requesting inter-agency guidance regarding the treatment of derivatives contracts referencing alternative risk-free rate benchmarks and associated transitions from interbank offered rates under the Title VII of the Dodd-Frank Act and associated regulations.

This report summarizes the choice of the Secured Overnight Financing Rate (SOFR) as its recommended alternative to USD LIBOR and enhancing the ARRC's Paced Transition Plan seeking to promote the use of SOFR on a voluntary basis.

This report summarizes the ARRC's progress in narrowing the set of potential rates that might be chosen as an alternative to USD LIBOR and in considering potential plans for transition to the chosen rate.

• Frequently Asked Questions on the Interim Report
• Comments Received on the Interim Report